Virginia L. Dimon - Page 7

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          we agree with respondent.6  On that record, we find that respon-            
          dent has satisfied respondent’s burden of production under                  
          section 7491(c) with respect to the additions to tax at issue in            
          these cases.  Petitioners have the burden of establishing that              
          they are not liable for those additions to tax.  See Higbee v.              
          Commissioner, 116 T.C. 438, 446-447 (2001).  Mr. Dimon testified            
          that he did not file a return for 1996 because some unidentified            
          person advised him that the $127,970 that he received during 1996           
          represented proceeds from the sale of a business, and not earned            
          income.  We shall not rely on Mr. Dimon’s general, conclusory,              
          and uncorroborated testimony as to the reasons why he did not               
          file a return for 1996 or pay estimated tax for that year.  On              
          the record before us, we find that petitioners have failed to               
          show that they are not liable for the additions to tax under                
          sections 6651(a)(1) and 6654 that respondent determined in the              
          respective notices issued to them.                                          
               We have considered all of the contentions and arguments of             
          petitioners that are not discussed herein, and we find them to be           
          without merit and/or irrelevant.                                            
               To reflect the foregoing,                                              

                                        Decisions will be entered under               
                                   Rule 155.                                          

               6The record establishes that neither Ms. Dimon nor Mr. Dimon           
          filed a return for taxable year 1996 and that neither of them               
          made any estimated or other tax payments for that year except for           
          $94 which was withheld from Ms. Dimon’s wages.                              

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